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Next Generation Governance Emerging Trends in Climate Position StatementsA GUIDE
Brandon ToewsStephanie Bertels
EMERGING TRENDS IN CLIMATE POSITION STATEMENTS 2
Next Generation Governance:Emerging Trends in Climate Position Statements
Prepared by Brandon Toews and Stephanie Bertels
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Toews, B., and Bertels, S. (2019) Next Generation Governance: Emerging Trends in Climate Position Statements. Embedding Project.DOI 10.6084/m9.figshare.8859527
EMERGING TRENDS IN CLIMATE POSITION STATEMENTS 3
Introduction 4
Why position statements? 4
Why a climate change position statement? 5
Climate change position statements and TCFD disclosure 6
Developing your position statement 7
Explain the issue 7
Link the issue to your strategy 11
Clarify your commitments 15
Keep it short and accessible 18
Acknowledgements 20
Contents
EMERGING TRENDS IN CLIMATE POSITION STATEMENTS 4
This guide focuses on emerging trends in climate position statements and makes
use of a three-step process outlined in our Guidebook on Developing Position
Statements on Sustainability Issues.
To assemble this guide, we reviewed over two thousand climate change position
statements from a wide range of geographies and industries and spoke with over 200
directors. Through our analysis, we have identified examples of how companies are
explaining the issue of climate change, linking the issue of climate to strategy, and
clarifying their climate commitments.
We hope this guide is helpful to you in constructing your own climate position
statement.
In the past, it has been common for companies to issue broad positions on
environmental management, sustainability, or corporate responsibility that address
multiple (and often overlapping) environmental, social, and governance (ESG) issues.
Too often, the result has been lengthy documents that fail to make a clear strategic
connection between specific issues and their implications for business decision-
making.
Yet, as stakeholder expectations for corporate social and environmental responsibility
expand and intensify, companies are under increasing pressure to clearly convey their
position on a range of important ESG issues, including specifically addressing the
company’s understanding of the context in which it operates and clarifying its role
and commitments to address these challenges.
Introduction
Why position statements?
EMERGING TRENDS IN CLIMATE POSITION STATEMENTS 5
In our conversations with leading directors, we heard that by developing more
contextual position statements, focused on specific issues like climate change, boards
and executive teams can deepen their understanding of these issues, clarify how
they link to the company’s overall strategy, provide the direction and confidence
for management and employees to act, as well as clarify their position for other key
stakeholders. We also heard multiple requests for better guidance on how to develop
a comprehensive yet concise position statement.
Why a climate change position statement?The consensus on climate science is unequivocal: it is happening, it is global, the
consequences are severe and intensifying, and anthropogenic causes are the driving
force.1, 2 Prompt and effective action from corporations, world governments, and
communities towards limiting GHG emissions is not only essential – it’s overdue.
The international business community is also witnessing an emergent and related
cross-industrial trend: companies voluntarily disclosing their climate-related risks in
alignment with the recommendations of the Task Force on Climate-Related Financial
Disclosures (TCFD).3 As described in the section below, the TCFD aims to bring
greater transparency to climate-related risks. While currently voluntary, it is expected
that regulation on mandatory climate risk disclosure is sure to follow.
1 https://www.ipcc.ch/site/assets/uploads/2018/02/AR5_SYR_FINAL_SPM.pdf2 https://climate.nasa.gov/evidence/3 https://www.fsb-tcfd.org
EMERGING TRENDS IN CLIMATE POSITION STATEMENTS 6
The taskforce for climate-related financial risk disclosures (TCFD) was set up to help
investors understand their financial exposure to climate risk and help companies
disclose this information in a clear and consistent way within their mainstream filings.
After extensive consultation, the TCFD released recommendations in 2017 that
encourage businesses from all sectors to assess and disclose climate-related financial
risks, along with their strategies for dealing with the impacts of climate change,
and to voluntarily integrate this information into their financial filings and existing
disclosures.
The TCFD recommendations place considerable emphasis on undertaking scenario
analysis to consider how climate-related risks and opportunities may emerge and
evolve to impact business strategy. Companies should describe the resilience of
their strategies through climate-related scenarios, including ones that explore the
requirements of a 2.0 oC or lower emissions trajectory and the consequences of
higher emissions trajectories. These scenarios include looking at the potential impact
of carbon regulation and carbon pricing, increasing extreme weather events, and
declining access to non-renewable energy sources.
At the time of this guide’s release, the four primary documents released by the
Task Force include a recommendations report, a guide on implementing the
recommendations, a technical supplement on using scenario analysis, and a 2018
status report. We recommend that you read them prior to developing or updating
your climate change position statement.
Climate Change Position Statements and TCFD Disclosure
EMERGING TRENDS IN CLIMATE POSITION STATEMENTS 7
Developing your position statement
Explain the issueExplain your understanding of climate change, outlining key trends.
From our review of over two thousand climate positions statements, we found that
companies are now routinely acknowledging their acceptance of climate science.
For instance, they routinely acknowledge that rising concentrations of CO2 are
causing climate change and that human activities are driving this trend. They also
acknowledge that climate change is increasing the occurrence of extreme weather
events and that as a result the global community is now threatened by significant and
potentially irreversible social, environmental, and economic repercussions.
Example 1: “We recognise scientific work undertaken by the Inter-Governmental
Panel on Climate Change in its Fifth Assessment Report. Consequently, we
accept that the global climate is changing due to human actions, principally the
burning of fossil fuels, and that it will continue to change throughout the 21st
century”4 (Old Mutual)
4 https://www.oldmutual.com/docs/default-source/responsible-business-files/our- carbon-commitment/climate-change-position-statement.pdf?sfvrsn=c1a26cbb_2
explain the issue
link the issue to your strategy
clarify your commitments
keep it short and accessible
EMERGING TRENDS IN CLIMATE POSITION STATEMENTS 8
Example 2: “The accumulation of greenhouse gases (GHGs) in our atmosphere
has led to noticeable changes in natural systems, including changes to migration
patterns and growing seasons. Ocean acidification and increasing ocean
temperatures are damaging marine ecosystems. Rising sea levels are increasing
risks to coastal communities and commercial facilities. Further still, the increased
frequency and severity of extreme weather events are putting many more at
greater risk, irrespective of location”5 (Dell)
Example 3: “According to UN’s Intergovernmental Panel on Climate Change
(IPCC), the average surface temperature has risen 0.6-0.9 of a degree Celsius
worldwide in the past century, and consequences have already been observed
across continents and oceans. The International Monetary Fund estimates
that further increases in temperature may pose the largest threat to the world
economy in the 21st century, and scientists and organisations such as IPCC believe
that only substantial and sustained reductions in greenhouse gases will stop
global warming”6 (Danske Bank)
Going forward, we expect that climate position statements that do not explicitly
acknowledge their acceptance of climate change and its impacts will be viewed
with skepticism by stakeholders, including investors. Further, as more municipalities
and nations declare climate emergencies, companies will face growing pressure to
articulate a position on how they will respond.
5 https://www.dell.com/learn/us/en/uscorp1/corp-comm/climate- policy?c=us&l=en&s=corp6 https://danskebank.com/-/media/danske-bank-com/file-cloud/2017/5/ danske-bank-position-statement-climate-change.pdf
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Explain your understanding of the relevant environmental or social limits beyond which the resiliency of the system is threatened, referencing key sources of authority as well as your rationale for selecting them.
Corporate sustainability leaders are clearly articulating their understanding of the
pace at which climate action needs to be taken and the scale of the global transition
required to achieve it. Companies now routinely reference the International Panel
on Climate Change (IPCC) scenarios, the Paris Agreement, and/or national climate
reduction targets when explaining their understanding of relevant limits. In late 2018,
the IPCC7 announced scientific consensus on the need for a 1.5 °C target, noting
that hitting the 2 °C threshold would put millions more people at risk of death,
poverty, water and food shortages, and displacement from rising sea levels, while
increasing the odds of irreversible changes in our climate system. In the wake of this
announcement, leading companies are now committing to holding temperature rise
below 1.5 °C, which includes reducing emissions from 2010 levels by 45% by 2030,
and aiming to reach net zero by 2050.
Example 1: “To reduce the risks and impacts of climate change, 194 countries
signed the Paris Agreement, including and since ratified by Australia, committing
to strengthen the global response to climate change by “holding the increase
in global average temperatures to well below two degrees Celsius above pre-
industrial levels and to pursue efforts to limit the temperature increase to 1.5
degrees Celsius… [We] recognize the importance of limiting global warming to
two degrees and that to do this global emissions need to reach net zero in the
second half of his century.”8 (Westpac)
Example 2: “…[A] growing number of scientists point out that the safe upper limit
of global warming is 1.5 degrees Celsius, or around 350 ppm. Scientific research
has revealed that the damage caused at a temperature rise of 2 degrees Celsius
or more may be much greater than previously assumed.”9 (ASN Bank)
7 http://www.ipcc.ch/report/sr15/8 https://www.westpac.com.au/content/dam/public/wbc/documents/pdf/aw/ sustainability/WestpacCCEActionPlan.pdf9 https://www.asnbank.nl/web/file?uuid=a9281b2d-2454-47d2-a773-ee420f5f02 ed&owner=6916ad14-918d-4ea8-80ac-f71f0ff1928e&contentid=713
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Example 3: “The Carlsberg Group has worked with Carbon Trust, the independent
not-for-profit expert, to set science-based targets for emission reductions at a
level that would contribute to limiting global warming to 1.5 °C, the higher level
of ambition contained within the Paris Agreement… ‘Just getting better is no
longer good enough. Carlsberg’s ambitions go above and beyond the levels
of carbon reduction that science tells us are necessary to keep global warming
below 2 degrees Celsius.”10 (Carlsberg Group)
Ideally, your position statement should reference your climate scenario analyses work
to explain how your company is conceptualising limits for climate change and to
explain your rationale for the limits that you have selected.
As a result of your understanding of these limits, explain what collective action needs to be undertaken at a global, national, regional, or local level.
The majority of climate policy statements acknowledge that action must be taken
at a global level to reduce atmospheric CO2, with many companies calling upon
governments to create policy frameworks or voicing the need for industry-wide
action. We found that leading statements were more specific about the company’s
role in influencing and collaborating with communities, governments, partners, and
competitors, both towards building capacity to address climate change (internally,
and within their value chain) and in developing, implementing, sharing, and
encouraging reduction plans.
Example 1: “To effectively address such a vast range of impacts, mitigation and
adaptation strategies must link regional, national and sub-national efforts through
collaboration with governments and policy bodies, public-private partnerships,
and initiatives between commercial entities.”11 (Dell)
10 https://carlsberggroup.com/newsroom/carlsberg-to-achieve-zero-carbon- emissions-at-its-breweries-by-2030-as-part-of-industry-leading-sustainability-ambitions/11 https://i.dell.com/sites/content/corporate/corp-comm/en/Documents/ DellClimatePolicyPrinciples.pdf
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Example 2: “Staying below a temperature rise of 2 °C will require a profound
change in development models. This global challenge requires a multi-level
approach combining governments, civil society and business efforts. Together we
must cut emissions and work with farmers to build resilience to climate change.”12
(Danone)
Example 3: “All African countries in which Nedbank operates have formally
committed to addressing climate change as signatories to the Paris Agreement.
South Africa in particular has unacceptably high carbon emissions and urgently
needs to reduce its dependence on fossil fuels while adapting to unavoidable
climate change impacts. It is the responsibility of all businesses – whether they are
carbon-intensive or not – to collaborate with government and other stakeholders
to help meet domestic and international objectives.”13 (Nedbank)
Link the issue to your strategy Link this issue to the strategic impact it could have on your own business, including relevant risks and opportunities.
A growing number of companies are realising that they must move beyond the
mindset of ‘what can we do?’ to ‘what do we need to do?’ and are transparently
articulating the impact that climate change could have on their strategy. Industry
leaders are acknowledging the constraints and opportunities that may result from
adhering to limits, and the unavoidable risks that will result from inaction. In our
conversations with senior executives and board directors, many expressed strong
support for this level of transparency and emphasised the importance of publicly
declaring how their company’s long-term success is dependent on operating within
sustainable social and environmental limits.
12 https://www.danone.com/content/dam/danone-corp/about-us-impact/ policies-and-commitments/en/2016/2016_05_18_ClimatePolicy.pdf13 https://www.nedbank.co.za/content/dam/nedbank/site-assets/AboutUs/ Sustainability/Supporting%20Documents/ClimatePosition2019%209May2019.pdf
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Example 1: “As a global food company, General Mills recognizes the risks that
climate change presents to humanity, our environment and our livelihoods.
Changes in climate not only affect global food security but also impact General
Mills’ raw material supply which, in turn, affects our ability to deliver quality,
finished product to our consumers and ultimately, value to our shareholders.”14
(General Mills)
Example 2: “We have assessed the risks associated with climate change and their
potential impact on our business. Physical risks include supply chain disruption
due to severe weather impacting a facility, or commodity disruption for specific
geographically concentrated ingredients such as cocoa from West Africa or
almonds from California. We have active mitigation plans in place to address
and minimize these types of disruptions. Reputational risks could arise from not
addressing the emissions in our supply chain. We are doing our part to reach
an aggressive greenhouse gas (GHG) emissions reduction target and positively
influence the broader value chain.”15 (General Mills)
Example 3: “Climate change influences our global business strategy due to its
direct impact, risks, and opportunities. Our energy and climate change strategy
fosters value creation in the long term through effective risk management and
by taking advantage of the opportunities… The most significant risks are related
to extreme weather events and, in the midterm, temperature increase. An
increase in temperature could affect the energy consumption of our infrastructures
for additional cooling needs, but also we could have indirect risks related with a
potential increase in the energy costs, dependent on the hydroelectric power in
some countries.”16 (Telefónica)
14 https://www.generalmills.com/en/News/Issues/climate-policy15 https://globalresponsibility.generalmills.com/HTML1/general_mills-global_ responsibility_2019_0026.htm#3 16 https://www.telefonica.com/en/web/responsible-business/environment/energy-and-climate-change-2?p_p_id=2_WAR_kaleodesignerportlet&p_p_lifecycle=0
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In alignment with the TCFD recommendations, your company should identify the
climate-related risks it has identified over the short, medium, and long term. Explain
the strategic impact these risks and opportunities could have on your business
and describe the resilience of your company by taking into consideration different
climate-related scenarios, including a 2o C limit or lower scenario.
Example: “We use scenario planning to assess the future and believe that the
“autonomy” scenario best represents the technology and policy context that
would be essential to meet “450 ppm.” However, all of our scenarios point to
the need for us to continue to aggressively lower costs and carbon intensity
throughout our business. This is not only good for the environment but we believe
it is also good for business.”17 (Suncor)
Your position statement will benefit from performing scenario analysis both prior
to and during development. Scenarios are a useful and well-established tool for
developing input for strategic planning, and particularly for evaluating present and
future potential risks and opportunities. They enhance the flexibility and resiliency
of corporate climate strategies and inform stakeholders of the ways in which your
company is positioning itself in light of future climate-related uncertainty.
Discuss your company’s understanding of its relevant direct and indirect impacts.
Companies are becoming increasingly transparent when reporting on their
contributions to the issue of climate change, and in explaining how they determined
what is within their responsibility to address. For example, thousands of organisations
around the world are using the Greenhouse Gas Protocol’s concept of Scope 1,
2, and 3 emissions, with many now highlighting their most impactful activities.
Companies leading in sustainability are also exploring and reporting on the full
lifecycle implications of their products and services, from material sourcing to
disposal or repurposing and releasing more detailed data on their direct and indirect
impacts on climate change.
17 https://www.nrcan.gc.ca/sites/www.nrcan.gc.ca/files/energy/energy-resources/ Suncors_Climate_Report_(2017)_-_Resilience_Through_Strategy.pdf
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Example 1: “General Mills has assessed that 92 percent of the GHG emissions
associated with our value chain can be considered Scope 3 - occurring in entities
not owned or controlled by the company. Nearly 2/3 of the GHG emissions
and 99 percent of water use throughout our value chain occur upstream of our
direct operations in agriculture, ingredients and packaging. This is where we can
achieve the greatest reduction in our environmental footprint while ensuring the
long-term availability of ingredients.”18 (General Mills)
Example 2: “We recognize that upstream agriculture emissions and our
manufacturing are the largest sources of emissions in our value chain and
will focus on efforts on achieving emissions reductions in these two areas.”19
(Kellogg’s)
Example 3: “Mars’ full value chain GHG emissions in 2015 were estimated at 26.2
million tonnes of carbon dioxide equivalent (MtCO2e) – approximately equivalent
to the emissions of Panama (WRI, 2017). While energy use is a significant driver
of our operational emissions, agriculture and land use change emissions make up
the lion’s share – approximately 75% – of our full value chain emissions.”20 (Mars)
18 https://www.generalmills.com/en/News/Issues/climate-policy19 crreport.kelloggcompany.com/download/Kellogg+Climate+Policy+Methodology.pdf20 https://www.mars.com/global/about-us/policies-and-practices/ climate-action-position-statement
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Clarify your commitmentsClarify your commitment(s) to operate within relevant limits, addressing those impacts that are within your direct control and acknowledge how these commitments will shape your future action.
Senior executives and directors have become increasingly aware of how important
transparency and precision are when clarifying commitments. While many of the older
climate position statements that we reviewed did not include specific commitments,
more recently published position statements generally include credible, contextual
commitments to align with a particular climate scenario, the Paris Agreement, and/or
national commitments.
Example 1: “The company has committed to reduce by 32% the emissions of
scopes 1 and 2 (those generated by its own activity) until 2030, using 2009 as
its base year. This is equivalent to reducing emissions by 42.9% for every million
euros of revenue. It also undertakes to reduce scope 3 emissions (indirect,
excluding capital goods, purchased goods and services) by 20% until 2030, using
2012 as the base year.”21 (Ferrovial)
Example 2: “We have committed to setting science-based targets line with the
globally agreed 2 °C. Our commitment is to reduce our relative footprint by 50%
by 2020 from a 2004 baseline. This will be enabled by taking up opportunities
to invest in and implement processes and technologies within our operations
to reduce our overall carbon footprint. We will also leverage on the successes
of some of our current projects to further reduce energy use in our direct
operations.”22 (Woolworths)
21 https://www.ferrovial.com/en/our-commitment/environment/climate-change/ carbon-reduction-objectives/22 https://www.woolworths.co.za/images/elasticera/New_Site/Corporate/ Woolworths_Climate_Change_Position_Statement.pdf
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In alignment with TCFD recommendations, your position statement should identify
the metrics used by your company to assess climate-related risks and opportunities
(such as tonnes of carbon dioxide equivalent (tCO2e) per unit of production). Your
position statement should also explain the targets used to manage climate-related
risks and opportunities and performance against these targets.
Clarify your commitment(s) to influence and support the actions of others in your value chain, in your industry, and/or in your investments and acknowledge how these commitments will shape your future action.
Leading companies are clarifying their role and responsibility in helping others within
their value chain to also adhere to limits in order to reduce the impact of their indirect
activities. Hundreds of organisations have determined their Scope 3 emissions, and
a growing number are disclosing their investments and funding initiatives whose
activities align with their climate commitments.
Example 1: “In order to be Sustainable in a Generation, we’ve looked at the
best-available science. It tells us we must reduce the total GHG emissions across
our value chain by 27% by 2025 and 67% by 2050 (from 2015 levels) in order to
do our part to keep the planet from warming beyond two degrees. So, that’s our
goal.”23 (Mars)
Example 2: “We are directing a significant and growing proportion of
our funding to help transform the economy at a rate that is commensurate with
UNFCCC objectives. Since the African continent is extremely vulnerable to the
negative impacts of climate change, our response includes both mitigation and
adaptation components, comprising decarbonisation of our lending book in
line with the required trajectory and increased funding to enable sustainable
development, including provision of modern energy services, clean water and
sanitation, climate- resilient infrastructure and sustainable cities.“24 (Nedbank)
23 https://mars.no/sustainable-in-a-generation-plan/healthy-planet/climate-action24 https://www.nedbank.co.za/content/dam/nedbank/site-assets/AboutUs/ Sustainability/Supporting%20Documents/ClimatePosition2018.pdf
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Be clear about sign-off, oversight, implementation, and reporting.
Unfortunately, in the vast majority of climate change position statements that we
reviewed, there was no indication of who signed off on the statement or when the
statement came into effect. Be explicit about whether your position statement has
received the endorsement of management and/or the Board and include the date of
sign-off.
In alignment with the TCFD recommendations, your position statement should
identify the parties responsible for overseeing any commitments made in the
statement and should clarify management’s role in assessing and managing climate-
related risks and opportunities. Your position statement should also clarify any
expectations around reporting and/or links to compensation.
Example: “The following senior leaders are involved in implementing the
management of energy and greenhouse gas emissions: The Senior Vice President,
Sustainability and External Affairs reports directly to our CEO and is responsible
for sustainability, health and safety, environment and community affairs, including
energy and greenhouse gas emissions. The Vice President, Environment oversees
compliance with environmental standards for projects, operations and our legacy
properties, and regularly reviews environmental performance risks and strategic
issues. The Vice President, Community and Government Relations is involved in
engaging provincial and federal governments on climate policy. The Manager
of Sustainability Implementation and Carbon Strategy coordinates the risk and
opportunity management for climate-related risks and the implementation of our
climate action strategy and energy and GHG reduction goals.”25 (Teck)
Commit to a transparent cycle of review and include a timeline for the next review of
this statement.
25 https://www.teck.com/media/teck_approach_to_energy_climate_change.pdf
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Where possible, articulate a pattern of decision-making.
Finally, you can provide examples of prior decisions that are aligned with your
commitment(s) to help create a compelling and credible narrative that conveys a
pattern of acknowledging the issue and acting to do your part in addressing it.
Consider highlighting and explaining initiatives, memberships, partnerships, and early
or external commitments that help illustrate the maturation arc of your company’s
climate strategy.
Example: “In 2008, Kellogg committed to reducing our normalized energy usage,
greenhouse gas (GHG) emissions, water usage, and waste to landfill 15-20% by
2015 (from a 2005 baseline)… Through these commitments, we have already
delivered Scope 1 and 2 absolute emissions reductions from manufacturing of
approximately 12%.”26 (Kellogg’s)
Position statements should provide clear guidance and direction to your company
with respect to relevant environmental, social, or governance issues. A common
problem with position statements we reviewed is that they were hard to locate, too
long (sometimes dozens of pages), difficult to navigate, and often contained too
much extraneous information.
Make sure your document is publicly accessible.
Position statements should be concise and accessible, both in terms of the language
used and also in terms of locating them. Your climate change position statement
should be publicly available, for instance by including it in the sustainability and/or
governance section of your company’s website.
Example: DuPont consolidates its position statements into a single web-page,
noting “Position statements represent DuPont’s informed views and opinions
on industry-related issues. They cover a range of topics that reinforce our
commitment to sustainable growth and are important to stakeholders.”27 (Dupont)
Keep it short and accessible
26 crreport.kelloggcompany.com/download/Kellogg+Climate+Policy+Methodology.pdf27 http://www.dupont.com/corporate-functions/our-company/insights/articles/ position-statements.html
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Avoid reporting on short-term performance or discussing awards or accolades.
While it is important to reference overall trends in your past performance and
patterns of decision-making, we recommend that you save reporting on recent
performance, achievements to date, awards and accolades, and unrelated
sustainability initiatives in your annual sustainability reports or your website.
Consider briefly addressing what motivated the statement and/or the process that led to its development.
Consider including a section that outlines the motivation for this position statement
and/or the process that led to its development. Provide a brief background on why
and how the position statement came to be. Were there specific questions, learning
outcomes, or impacts that motivated this statement? For instance, if your position
statement was created in response to investor demands, you might include: “This
position statement was motivated by shareholder concerns over the strategic impact
and financial implications that climate change and extreme weather events may have
on our future success.”
Is your company in the process of developing or revising an ESG position
statement? Or has your company recently developed one? Either way, reach
out to us. We would love to hear from you! [email protected]
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Acknowledgements
The Embedding Project is hosted by the Beedie School of Business at Simon Fraser University.
This research was supported by the Social Sciences and Humanities Research Council of Canada
CPA Canada
and contributions from our partner companies:
https://www.embeddingproject.org/our-community